Ponzi Payouts Were Not Money Laundering

A defendant’s payouts as a return on investment to two early investors in his Ponzi scheme were “essential expenses” of his underlying fraudulent scheme and the 4th Circuit vacates defendant’s money-laundering convictions based on these payments, but affirms defendant’s securities and wire fraud convictions and remands for resentencing.
The federal promotional money-laundering statute, 18 U.S.C. § ...